Tax avoidance and tax evasion cause major problems to the assessment and collection of tax and invariably attack the integrity of any tax system. Denis Healey, former UK Chancellor of the Exchequer once said “The difference between tax avoidance and tax evasion is the thickness of a prison...

Businesses that embark on major capital investments can incur substantial feasibility expenditure. One challenge they may face is that such expenditure although clearly business related is non-deductible. Among tax people this is known as expenditure which has fallen into a tax "black hole"....

Global business does its tax planning on an international and multi-jurisdictional basis. Tax Authorities however have remained sovereign and focused on their own tax base. Current economic conditions have sharpened this focus to an acute extent. Tax authorities respond to international tax...

This article tries to find a new way through old arguments about whether or not New Zealand should have a realization-based capital gains tax. Instead of revisiting the first-principles analysis of the costs and benefits of a capital gains tax, it starts by observing that many countries have...

This article considers the nature of the relationship between domestic thin capitalization rules and the non-discrimination article in the OECD Model, with a particular focus on foreign ownership and article 24(5). In this context a question arises regarding the interpretation of article 24(5)...